ML20012E003
| ML20012E003 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/22/1990 |
| From: | Walt T PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003290204 | |
| Download: ML20012E003 (4) | |
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WW MCommuy March 22, 1990
. Trojan Nuclear Plant -
l Docket 50-344 i
-License NPF-1 l
o
.U.S.' Nuclear Re5ulatory Commission l
ATTN Document Control Desk' Washington DC 20555.
Dear Sir:
I-
'Repiv to'a Notice of Violation transmitt'd'one Notice of Violation Your letter of' February 20, 1990 e
associated with Nucicar Regulatory Commission Inspection Report 50-344/89-31.
t.
The subject violation-(50-344'/89-31-01) was noted as being similar to a
. previous violation-(50-344/89-24-02). The previous violation took place on
' September 19, 1989 and was responded to on December 18, 1989.
Since the current violation-(89-31-01) took place on May.5. 1989 the corrective ~
actions for the previous violation could not have prevented.its occurrence ~
Sincerely,
~
T.
D., Walt. Acting l:
Vice-President, Nuclear Attachment l
!J
' 'Mr.. John B.' Martin c:
l Re51onal. Administrator, Region V r
U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith o
l State of Oregon L
Department of Energy l
Mr. R. C. Barr1 l:
NRC Resident Inspector L.
Trojan Nuclear Plant
.'9003290204 900322 7
0 PDR ADOCK 05000344
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121 S.W Safmon Street, Portland. Oregon 97204
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Tr'ojan Nuclear Plant.
Document Control Desk?
. Docket 50-344 March 22, 1990 License NPF-1 Page 1 of 3 NOTICE OF VIOLATION j
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Violation During an NRC inspection conducted from December 4, 1989 through January 31, 1990, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action", 10 CFR Part 2, Appendix C (1989), the violation is listed below:
10 CFR 50 Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions,.
procedures. or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions,.
procedures.or drawings."
l Trojan Maintenance Procedure MP 2-0, " Installed Plant Instrument Maintenance and Calibration", Revision 12, effective date-September 21, 1989 Section Note 6.2.6.d. states in part, "If the as-found-readings for quality-related instruments are outside the stated tolerance.
. the I&C technicit.,shall.
. bring it to the attention of'the I&C. supervisor or his designee.
They shall initiate a Form I&C-10, Installed Instrument Out-of-Calibration Investigation (see Section 6.3) for Quality-related Instruments".
- Contrary to the above, on May 5, 1989, when the Emergency Diesel Generator lube oil filter inlet temperature instrument (No. TI-3821X) lf failed its scheduled calibration test, a Form-I&C-10 was-not initiated.
This is a repeat Severity Level IV Violation.
Response
Portland General Electric Company (PGE) acknowledges the violation.
A.
Reason for the violation:
p The reason for the violation is personnel error in failing to recognize that the out-of-tolerance condition required the initiation of an out-of-calibration investigation (I&C Form 10).
The I&C Technician Who performed the calibration and the I&C Supervisor who reviewed the calibration results did not consider the out-of-tolerance condition to require the initiation of an I&C Form 10 since a " Limited Use" sticker was applied to the instrument.
The application of a " Limited
i i
Trojan Nuclear Plant Document Control Desk.
Docket 50-344' March 22,-1990
- Li6ense NPF-l' Page 2 of 3
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Use" sticker. certified that the instrument was in ' calibration over the range of temperatures that are experienced When the Emergency Diesel.
Cenerator is in operation.
B.
- Corrective steps that have been taken and the results achieved:
.1.
An I&C Form 10 was initiated by the I&C Department.
The conclusions of the out-of-calibration investigation are as follows:
a.
For the specified accuracy of +/- 5*F, the only point out-of-tolerance is the low end of the scale at 110 degrees F.
b.
The normal temperatures which this indicator monitors.are
-approximately 125'F in the standby mode and 190*F in the running
- mode, c.-
In the running mode range, the indicator is within the stated I&C Form 4 card accuracy.
However, at the low end of the scale the indicator will read approximately 7' higher than the actual temperature (2'F above tolerance).
In the standby mode, therefore, the indicator could possibly read out of tolerance high.
d.
This out-of-calibration did not affect the operability of the emergency diesel generator.
This indicator provides local temperature indication and is used primarily for trending.
The offset due to this out-of-calibration dous not affect the ability to trend the lube oil temperature.
2.
A formal review of this event was included with the discussion of a similar violation from NRC Inspection Report 50-344/89-24. This review took place during the first quarter I&C Maintenance Annual Training held on March-8 & 9 1990.
3.
A review of MP-2-0 requirements was also covered during the first quarter I&C Maintenance Annual Training described above.
C.
Corrective steps that will be taken to avoid further violations:
l 1.
Plant Systems Engineering will perform an evaluation for increasing the acceptable tolerance of this type of temperature indicator to a value that is within the calibration capability of the temperature instrument.
This evaluation will be completed by September 30, 1990.
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_, ~ Docket 50-344 March 22, 1990 License NPF-1
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Date when full compliance will be achieved:
Full compliance was achieved on January 9, 1990, upon completion of the out-of-calibration investigation.
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